‘I had just appeared in the final of The Observer national mooting competition and was sitting at the dinner next to a High Court judge. He was talking. As an eager law student with ambitions to go to the Bar, I was listening [but] feeling really queasy. I was too polite to interrupt and say, “Excuse me, I must dash to the loo!” I jumped up (too late) and vomited over his shoulder! I wrote a letter of apology to him. He replied kindly. Later I would see him at Lincoln’s Inn, walking to lunch with two fellow Court of Appeal judges. I imagined him saying to them, “That’s the girl who threw up over me!”’

I am talking with Sara Lawson QC, first female General Counsel of the Serious Fraud Office. At the time of that mooting final she was studying business law at the then Huddersfield Polytechnic law school. ‘It was the smallest law school in the country, with a practical focus. Business law, including finance and accountancy, proved helpful throughout my career. Of the students, over 20 progressed to the Bar. At Bar School I pursued the commercial option but was told at one of numerous interviews that I should “do family law as you won’t get a commercial pupillage”.’

A ‘formative experience’ in eight-year-old Sara’s life was the birth of a sister so seriously ill that her mother had to move into Great Ormond Street Hospital to look after her. ‘I would visit them with my father. I saw the loving care and the strain. Over the years I attended ten different schools in Kent and Sussex, always as “the new girl”; work was the one constant I could throw myself into. School was always a long drive away with my father, a former local politician. It was probably our debates in the car that led me to the Bar.’ Sara learned determination from her sister and mother, who had been in the Royal Ballet. ‘I went to every type of school: boarding school, comprehensive, and grammar school for my A levels where I wasn’t allowed to sit the Oxbridge exam because I came from a different school. Huddersfield was the first place where I started along with everyone else.’

As a student member of Inner Temple, Sara’s sponsor was Owen Davies QC, ‘a wonderful character and unconventional dresser’, later head of Garden Court Chambers and HHJ Davies QC. ‘On my first visit he emerged from his room to welcome me, wearing a Chairman Mao suit and slippers. He asked, “Have you thought about crime? No? Then come and spend two weeks on a mini-pupillage with me.” I experienced the excitement of a Crown Court trial and loved it – a real eye-opener. I said to him, “If I do crime, all my commercial law will go to waste.” He replied, “Do fraud – a mix of crime and commercial; do SFO work; apply to 5KBW [now Red Lion Chambers].” When I turned up for my interview, they were not expecting me. Someone purportedly representing me had phoned to cancel. Linda Dobbs, later the first non-white High Court judge, got me a scholarship; when my poly degree was questioned, Peter Rook QC, later head of Chambers, said, “A business law degree is just what we need.” I remained there for 29 years until coming here in 2019.’

Sara began her practice defending. ‘If I had been a man I would have got better work. I was conscious that I was building on the work of Chambers’ female role models. Linda Stern QC, first female tenant in 1972, had agreed to use the loo in Inner library so Chambers didn’t have to install one for women. Most of the women prosecuted; it was seen as fairer and more meritorious to get oneself onto a list. I was doing rape cases for the CPS alongside my SFO fraud work and prosecuting for government departments such as Customs & Excise and the Insolvency Service, later becoming their Standing Counsel. I delayed taking silk until 2017 because I enjoyed this work so much.’

When Sara got silk – ‘a dream come true’ – all was going well. ‘Then, two years later, I received a call from the Cabinet Office. Would I like to be considered for the GC role at SFO? I hesitated, feeling I was being put forward to make up the numbers on diversity.’ The process involved interviews, a legal test, a presentation, a staff panel and a clinical psychologist. What does the job entail? As counsel in an SFO case Sara would read every piece of the material when getting into her case. ‘As GC I don’t have time to do that. I talk with the case team and read their summaries, including of counsel’s advice. I help the team focus on the essentials, bringing to bear my experience of the reality of a criminal trial. Complex fraud investigations run the risk of getting out of hand. I seek to add reality by asking questions like: do we have enough to prosecute now, can we cut out what we don’t need, what would be the effect on sentence, are we making the best use of public money? Let’s look at what we are asking of the jury: are we picking our best case and presenting it clearly so the jury will understand and feel able to convict? I discuss our cases with the Director [Lisa Osofsky]. She makes the final decisions about whether to take on a case and what to charge. She brings her own thoughts to bear, from decades of trial experience.’

What’s the biggest challenge? ‘Sheer volume of information, including what is contained in the servers and digital devices that we seize. The average person has four devices. If printed, our material would stretch to the moon and back. Developments in using technology for document-handling are helping in dealing with the volumes of material. However, it is still people who make the decisions on disclosure after the technology has put the material into categories, often after hundreds of different searches.’

Sara doesn’t look to claim personal successes. ‘All results are a team effort and occur over long time frames. In my time the Unaoil £1.7 billion bribery case recently resulted in four convictions and sentences of imprisonment. This case was part-heard before the pandemic – we had only just got to the speeches. It took three months to get it going again, with the last bit being heard at the Old Bailey after huge efforts by the Court Service and judiciary. There was also the record-breaking Deferred Prosecution Agreement with Airbus: €991 million in the UK and €3.6 billion in total as part of the world’s largest global resolution for bribery, involving authorities in France and the US. We give more money to the Treasury than we cost. I’m a big supporter of DPAs. They are about getting companies to reform, to be good corporate citizens, to have better systems; and they save jobs.’

The SFO takes on the biggest, most complex economic crime cases. ‘Of course, this means there are disappointments – such as disclosure mistakes preventing our taking the Serco trial to a jury – but the victories are incredibly significant. We recently secured a guilty plea in our GPT case, for example, where the company admitted to corrupt practices to win contracts to provide communications services to the Saudi Arabian National Guard. The result is emblematic of our determination.

‘Owing to the nature of our operations, we don’t produce a list of all current cases; about 50 feature on the website. Our multidisciplinary teams collaborate with agencies and others across the world. The great majority of our cases involve events abroad, with so many variants. We follow laundered money along its lengthy journey. We accept the recent Supreme Court defeat in KBR Inc limiting our s 2(3) notices to exclude extraterritorial effect. There was a contrary argument, which had persuaded the courts below, and we had never stopped using Mutual Legal Assistance provisions to obtain information. We will carry on now. I wish I could tell you what we are investigating now but I can’t yet.’

What next for Sara? ‘This job wasn’t expected. I’ve not ruled out a return to practice, the judiciary, a law firm or other Civil Service roles. But first I would like to see some of my personal work here come to fruition. I have refreshed our counsel lists to get new and diverse people; just because you have not done fraud, it doesn’t mean you couldn’t persuade a jury. Fraud is seen as a male preserve; it would be gratifying to help change that.’

Sara is now Master of the Employed Bar at Inner. Her advice to those starting out? ‘Career paths aren’t smooth; work with what you have got; don’t be put off by not having an Oxbridge degree; there is lots of help out there for you from the Inns, including sponsorship schemes. In future I expect to see more movement between chambers and employment.’

After she took silk, Sara thought she had reached the heady heights but when she was being fitted for her court coat, ‘I was told I could only have hook and eye fastenings because I was female. For the actual silk ceremony, I had worn a borrowed coat with buttons, and rather liked it. But I was told by my tailor that a combination of convention and statutory instruments dating back to Victorian times ruled out buttons for women. These discussions continued for about six fittings, during which I mentioned the saga to a friend. She asked if she could tell her friend, Lady Hale, who thereupon wrote a lovely email of support. So in the end I got my buttons. Next year a female friend went in and asked about buttons. “Ah yes, Madam,” said the tailor, “we call that The Lawson. The style is quite popular now!”’ 

The SFO in year 2020-21:

  • Convictions secured: 5
  • Individuals and corporates charged, with trials to come: 20
  • Two DPAs, resulting in over £45m in fines, penalties and costs
  • Compensation for victims: over £220k recovered